UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON, D.C. 20460 

Mr. Marc Gross 

Fireaway Inc. 

5852 Baker Road 

Minnetonka, MN 55345 

/JUt 1 5 2013 

OFFICE OF 

AIR AND RADIATION 

Re: Incomplete SNAP Submission for Stat-X/Aero-K Condensed Aerosol System in Fire 

Suppression 

Dear Mr. Gross: 

Thank you for Fireaway Inc.'s submission to the Environmental Protection Agency (EPA). EPA 

established the Significant New Alternatives Policy (SNAP) program to implement section 612 

of the Clean Air Act. Your application received on May 23,2013 has been reviewed for 

completeness as part of the initial SNAP review. We have found the submission to be 

incomplete. The following information is necessary in order to allow the Agency to continue the 

review ofFireaway Inc.'s submission for Stat-X/Aero-K Condensed Aerosol System in fire 

suppression in normally occupied areas. 

1. Application CBI Claims. Please provide a public version of your initial application in 

which all confidential business information (CBI) is removed. We will need a version 

with all CBI removed to place in the public docket. Also, please substantiate your CBI 

claims. 

2. Use Information. In Part I, Number 4, Part A, you state that Stat-X will be used in 

normally occupied and normally unoccupied areas (shipboard machinery spaces, marine 

engine compartments, electrical cabinets, engine compartments, turbine enclosures, 

flammable liquid storage, remote cellular base stations). 

a. Please specify the normally occupied spaces in aircraft, ships, and vehicles for 

which Stat-X is proposed for use. Please also include the approximate minimum 

and average dimensions of these spaces, and anticipated rate of airflow in spaces 

where you propose to use Stat-X. 

b. In Part II, Section D, Number 3, you state that Stat-X systems are mounted in a 

distributed layout throughout the protected space. Please provide a description of 

the layout, including the number of generators included, where the generators will 

be located (e.g., ceiling, walls), approximate distance between generators, and the 

direction of the generator nozzles. 

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c. In Attachment 1, you indicate that Stat-X generators used in unoccupied spaces 

are triggered by thermal or electrical activation, depending on the model. Please 

clarify whether generators proposed for occupied spaces will rely on a manual or 

electrical discharge system, or both, and specify the release rate of the generator 

(g/sec ). 

3. Charge Size. In Part I, B, 2, c, you state that a 500-gram (l.llb) Stat-X generator can be 

used to protect a 265 ft3 space. Does 500 grams represent the average, minimum, or 

maximum charge size of a Stat-X generator? In your previous submission for unoccupied 

space use, you had indicated a standard design concentration of Stat-X generators to not 

exceed 100 g/m3 and averaging 75 g/m3

. Please confirm if these remain the same for the 

generators used in occupied spaces. 

4. Particle Size. In your previous submission for use in unoccupied spaces, you had 

indicated that the post activation product ofthe Stat-X generator is 30 percent gaseous 

and 70 percent particulate, and therefore the amount of particulate matter in the air could 

reach 70 g/m3

. You had also indicated that 97 percent of the particulate matter is less than 

5 J.lm and 76 percent is less than 3 J.lm. Please confirm that these are the particle sizes 

produced by the Stat-X generators used in occupied spaces. 

5. Safety Precautions. In your submission you state that discharge of Stat-X in occupied 

spaces reduces visibility in the protected space. In Part I, Section B, Number 1, your 

submission notes that NFP A 201 0 presents several approaches to facilitate safe egress of 

personnel. 

a. Specifically, what training; installation, use, and disposal guidelines; or other 

precautions will be provided for Stat-X generators? Please provide copies of any 

guidance. 

b. What is your estimate of the maximum egress time expected in situations where 

visibility is reduced in the protected space? Depending on your response to this 

question, we may request further information. 

6. CBI Claims for Additional Information. If you wish to claim any of the information 

submitted in response to the requests above as CBI, please provide two copies of your 

response, one containing CBI and one with CBI removed. 

Here is a summary of information concerning your submission: 

Substitute name: Stat-X/Aero-K Condensed Aerosol System 

Substance(s) the substitute will replace: Halon 1301 

Sector: Fire Suppression 

End-uses: total flooding applications in normally occupied and normally unoccupied areas 

New or retrofit usage: New 

Date received: May 23, 2013 

Status of submission: Incomplete 
Responses to these questions are necessary for us to begin our review. The information can be 

submitted via electronic mail or hard copy. If you have questions about your submission, please 

contact me at (202) 343-9445 or vondemhagen.rebecca@epa.gov. 

Sincerely, 

Rebecca von dem Hagen 

Alternatives and Emissions Reduction Branch 

Stratospheric Protection Division